Testun llawn:
Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 and Policy SG1 are of particular interest to our Client.
As a result, we offer the following for the Authority’s consideration, and Inspector’s in due
course.
Our clients made a formal Strategic Candidate Site Submission in August 2018, which was
referenced SR/159/007, seeking the allocation of their land (edged red on Plan A) for a mix
of residential development, areas of formal and informal amenity space, habitat
enhancement areas, as well as improvements to local pedestrian and cycle link provision
and linkages, as part of the Replacement Local Development Plan.
Plan A
The Site would serve the settlement of Tycroes and the surrounding area of the associated
Principal Centre (Cluster 3). The Strategic Candidate Site comprised of a series of existing
enclosures, with vehicular access gained off the access estate road shared with a recently
constructed residential development to its north east, although multiple pedestrian and cycle
linkages would also be available along all boundaries of the site. Locationally, the site is also
within close proximity to the range of community facilities and local services the settlement
and surrounding area has to offer.
Following its due consideration, the Council then excluded undeveloped element of the Site
from the proposed development limits for Tycroes in its 1st Deposit LDP, published in
January 2020 (Plan B).
Plan B
In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:
““Inclusion of the site in its entirety would have a detrimental impact upon the character and
setting of the settlement and would exceed identified housing need. In considering smaller
areas of the site for inclusion it is concluded that there is sufficient and more suitable land
available elsewhere in Tycroes to meet its housing needs.”
The above decision was somewhat puzzling and in our view erroneous, particularly as
alternative allocations within the settlement and wider growth area were clearly neither
appropriate nor deliverable. In addition, the assessment also clearly failed to take into
account the mix of proposed uses, that reflected the immediate and wider landscape setting.
As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:
“Inclusion of the site in its entirety would have a detrimental impact upon the character and
setting of the settlement and would exceed identified housing need. In considering smaller
areas of the site for inclusion it is concluded that there is sufficient and more suitable land
available elsewhere in Tycroes to meet its housing needs.”
As can be seen, the rationale presented by the Council replicates that at the 1st Deposit LDP
stage (impact on character and housing land supply), although when examined fully (see
below), they appear both illogical and erroneous. Specifically, we consider that alternative
allocations within the settlement and wider Principal Centre are neither appropriate nor
deliverable (see below). We consider therefore that the land edged red in Plan A, should be
allocated for residential development under the provision of Policy HOM1 and Policy SG1
of the Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Ecological Appraisals
- Transport Statement
- Indicative Master Plan
Response to Council’s Reasons for Non-Allocation of Site
Detrimental impact upon the character and setting of the Settlement
The first part of the Council’s rationale for the Site’s exclusion relates to the Council’s
perception that its development for the proposed mix of uses would lead to a “… detrimental
impact upon the character and setting of the settlement.”. However, beyond this statement,
the Council has provided no further explanation of what ‘detriment’ would occur and to which
elements of the settlements “… character and setting…”.
As the originally submitted supporting information (copy enclosed) illustrates, the Strategic
Alternative Site does not form part of nor does it adjoin any designated Conservation Area.
In fact, the nearest (Llandeilo) is located a considerable distance to the north. Furthermore,
the Site does not contain nor is it within sight of any Listed Building or Ancient Monument. In
summary therefore, the allocation of the Site for the proposed mix of uses, would not have
any detrimental impact on the character or setting of any nearby historic interest.
From a landscape designation perspective, the Alternative Strategic Site does not form part
of a National Park or Area of Outstanding Beauty. On a more local level, the current LDP
has not defined any part of the Site or surrounding area as part of a Special Landscape
Area. The allocation of the Site for the proposed mix of uses, would not therefore have any
detrimental impact on the character or setting of any national or local landscape designation.
In terms then of the physical form of the adjoining settlement of Tycroes, its historic evolution
has followed the principal access routes to, through and within it, with later more recent
development then taking place in a more ‘in-depth’ manner of these routes. To suggest then
that the development of the relevant elements of the Strategic Alternative Site would be
counter – and so detrimental – to this existing setting and character is illogical. The proposed
pattern would in fact mirror and compliment the existing pattern of the adjoining settlement
and the erroneous inconsistent decision to exclude the Site by the Council is in itself grounds
to highlight that the 2nd Deposit LDP is unsound.
Sufficient Residential Land Allocated Within Settlement
The second part of the Council’s rationale for the non-allocation of the site for residential
development is on the basis that it considers that alternative allocations within Tycroes and
the wider Principal Centre it forms part of will deliver sufficient housing for the town during
the Plan period.
Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:
Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.
In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
currently proposed allocations are undeliverable and that the Council’s assessment of the
Alternative Strategic Site was flawed.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for mixed use development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.
